[Servercert-wg] Ballot SC28v3: Logging and Log Retention

Tue Jul 14 10:31:39 MST 2020

> We kindly ask that there is some "quiet time", without having to vote for new ballots until September 1st. Are there any other Members that support this?

In our opinion, this “quiet time” is adequate.
Best,
Pedro

> On 13 Jul 2020, at 18:35, Dimitris Zacharopoulos (HARICA) via Servercert-wg <servercert-wg at cabforum.org> wrote:
> 
> HARICA has examined the volume of changes that are being proposed and we are having trouble keeping up with all the long discussions (on and off this list) and long threads.
> 
> We are still in the COVID-19 situation where most teams work remotely and also need to take care of elders, take vacation time and so on.
> 
> There is also a new ballot being prepared by the NetSec regarding offline CAs. Even this current ballot (SC28) is long and needs to be properly analyzed so we don't miss anything critical.
> 
> We kindly ask that there is some "quiet time", without having to vote for new ballots until September 1st. Are there any other Members that support this?
> 
> I appreciate the time and effort from the NetSec subcommittee for putting together these ballots and we definitely want to see forward progress. However, we need time to carefully review proposed changes before voting on them.
> 
> 
> Best regards,
> Dimitris.
> 
> On 2020-07-09 1:04 μ.μ., Neil Dunbar via Servercert-wg wrote:
>> Just making a complete resend so that all the corrected information is in the motion and the redline reflects that.
>> 
>> Neil
>> -----
>> This is an update to the original SC28 (to make it version 3), with some text which addresses an issue highlighted by Malcolm Doody.
>> 
>> The amended discussion document is attached to this email.
>> Principal changes:
>> 1) Moving text to make clearer =the scope of CA key/certificate event retention
>> Updated redline: https://github.com/cabforum/documents/compare/16a5a9b...neildunbar:498c5ad <https://github.com/cabforum/documents/compare/16a5a9b...neildunbar:498c5ad>
>> 
>> Purpose of Ballot:
>> 
>> The proposed changes seek to clarify the relationship between audit
>> logging obligations under Network and Certification System Security
>> Requirements and Baseline Requirements and to reduce the retention
>> period for log data, when appropriate. The proposed change also provides
>> clarification by specifically cross-referencing the Baseline Requirements.
>> 
>> The current log retention requirements for subscriber certificates
>> require certificate validation and certificate activity to be retained
>> for seven years, while the lifetime of a certificate is only two years.
>> There does not seem to be a justification for retaining logs three times
>> as long as the lifetime of the certificate. As certificate lifetimes
>> move to one year this further supports a reduction in log retention;
>> this ballot proposes a sorting of the logged events into logical
>> categories, together with a requirement of CAs to retain the data for
>> two years after the event has passed (as opposed to the blanket seven
>> years which exists as a duty currently).
>> 
>> The benefit of this ballot is to reduce data retention requirements for
>> those log elements which most CAs consider as having limited long-term
>> value. As an example, firewall and router activity logs are of
>> significant size and thus impose significant storage requirements. These
>> logs serve a benefit when investigating a potential security event,
>> however, these logs lose value with the passage of time. Logs containing
>> firewall traffic that is several years old provide little value in the
>> investigation of a contemporary incident. Additionally, certificate
>> validation and issuance logs have little value after a certificate has
>> expired. The log size for many CAs is measured in terabytes, each year
>> and the overhead of storing these logs and monitoring for compliance is
>> significant. The benefit for reducing retention is considered high.
>> 
>> The dicussion document which forms the basis of the ballot is attached
>> as a PDF to this email - previous attempts to link to the Google Drive
>> document ran up against permission problems in the past.
>> 
>> Proposal
>> 
>> The following ballot is proposed by Neil Dunbar of TrustCor Systems and
>> endorsed by Trevoli Ponds-White of Amazon and Dustin Hollenback of
>> Microsoft.
>> *— MOTION BEGINS —*
>> 
>> Delete the following Section 5.4.1. from the “Baseline Requirements for
>> the Issuance and Management of Publicly-Trusted Certificates”, version
>> 1.6.7, which currently reads as follows:
>> The CA and each Delegated Third Party SHALL record details of the
>> actions taken to process a certificate request and to issue a
>> Certificate, including all information generated and documentation
>> received in connection with the certificate request; the time and date;
>> and the personnel involved. The CA SHALL make these records available
>> to its Qualified Auditor as proof of the CA’s compliance with these
>> Requirements.
>> The CA SHALL record at least the following events:
>>  1. CA key lifecycle management events, including: 
>> a. Key generation, backup, storage, recovery, archival,
>> and destruction; and 
>> b. Cryptographic device lifecycle management events. 
>> 2. CA and Subscriber Certificate lifecycle management events, including:
>> a.  Certificate requests, issuance, renewal, and re-key requests,
>>  and revocation;
>> b.  All verification activities stipulated in these Requirements
>>  and the CA’s Certification Practice Statement;
>> c.  Date, time, phone number used, persons spoken to, and end
>>  results of verification telephone calls;
>> d.  Acceptance and rejection of certificate requests; Frequency
>>  of Processing Log
>> e.  Issuance of Certificates; and
>> f.  Generation of Certificate Revocation Lists and OCSP entries.
>> 3. Security events, including:
>> a.  Successful and unsuccessful PKI system access attempts;
>> b.  PKI and security system actions performed;
>> c.  Security profile changes;
>> d.  System crashes, hardware failures, and other anomalies;
>> e.  Firewall and router activities; and
>> f.  Entries to and exits from the CA facility.
>> Insert in Section 1.6.1 (Definitions)  of the “Baseline Requirements for the
>> Issuance and Management of Publicly-Trusted Certificates”, the following (after
>> the definition of “Certification Practice Statement”):
>> Certificate Profile: A set of documents or files that defines requirements for
>> Certificate content and Certificate extensions in accordance with Section 7 of
>> the Baseline Requirements. e.g. a Section in a CA’s CPS or a certificate
>> template file used by CA software.
>> Insert, as Section 5.4.1. (Types of events recorded) of the “Baseline Requirements
>> for the Issuance and Management of Publicly-Trusted Certificates”, the following:
>> Section 5.4.1
>> The CA and each Delegated Third Party SHALL record details of the actions taken
>> to process a certificate request and to issue a Certificate, including all information
>> generated and documentation received in connection with the certificate request;
>> the time and date; and the personnel involved. The CA SHALL make these records
>> available to its Qualified Auditor as proof of the CA’s compliance with these
>> Requirements.
>> The CA SHALL record at least the following events:
>> CA certificate and key lifecycle events, including:
>> Key generation, backup, storage, recovery, archival, and destruction; 
>> Certificate requests, renewal, and re-key requests, and revocation;
>> Approval and rejection of certificate requests; 
>> Cryptographic device lifecycle management events;
>> Generation of Certificate Revocation Lists and OCSP entries;
>> Introduction of new Certificate Profiles and retirement of existing Certificate Profiles.
>> Subscriber Certificate lifecycle management events, including:
>> Certificate requests, renewal, and re-key requests, and revocation;
>> All verification activities stipulated in these Requirements and the CA's Certification Practice Statement;
>> Approval and rejection of certificate requests; 
>> Issuance of Certificates; and
>> Generation of Certificate Revocation Lists and OCSP entries.
>> Security events, including:
>> Successful and unsuccessful PKI system access attempts;
>> PKI and security system actions performed;
>> Security profile changes;
>> Installation, update and removal of software on a Certificate System; 
>> System crashes, hardware failures, and other anomalies;
>> Firewall and router activities; and
>> Entries to and exits from the CA facility.
>> Delete the following Section 5.4.3. from the “Baseline Requirements for the Issuance
>> and Management of Publicly-Trusted Certificates”, version 1.6.7, which currently
>> reads as follows:
>> The CA SHALL retain any audit logs generated for at least seven years. The CA
>> SHALL make these audit logs available to its Qualified Auditor upon request.
>> Insert, as Section 5.4.3. Retention Period for Audit Logs of the “Baseline Requirements
>> for the Issuance and Management of Publicly-Trusted Certificates”, the following:
>> 
>> The CA SHALL retain, for at least two years:
>> 
>> CA certificate and key lifecycle management event records (as set forth in Section 5.4.1 (1)) after the later occurrence of:
>> the destruction of the CA Private Key; or
>> the revocation or expiration of the final CA Certificate in that set of Certificates that have an X.509v3 basicConstraints extension with the cA field set to true and which share a common Public Key corresponding to the CA Private Key; 
>> Subscriber Certificate lifecycle management event records (as set forth in Section 5.4.1 (2)) after the revocation or expiration of the Subscriber Certificate.
>> Any security event records (as set forth in Section 5.4.1 (3)) after the event occurred. 
>> Delete from “Network and Certificate Systems Security Requirements”, Version 1.3,
>> Section 3.b
>> b.  Identify those Certificate Systems under the control of CA or Delegated
>>     Third Party Trusted Roles capable of monitoring and logging system activity
>>     and enable those systems to continuously monitor and log system activity;
>> Insert new “Network and Certificate Systems Security Requirements”, Version 1.3,
>> Section 3.b with the following text:
>> 
>> b.  Identify those Certificate Systems under the control of CA or Delegated
>>     Third Party Trusted Roles capable of monitoring and logging system activity,
>>     and enable those systems to log and continuously monitor the events specified
>>     in Section 5.4.1 (3) of the Baseline Requirements for the Issuance and
>>     Management of Publicly-Trusted Certificates;
>> *— MOTION ENDS —*
>> 
>> Discussion (7+ days)
>> 
>> Start Time: 2020-07-09 17:00:00 UTC
>> 
>> End Time: 2020-07-15 17:00:00 UTC
>> 
>> Vote for approval (7 days)
>> 
>> Start Time : TBD
>> 
>> End Time: TBD
>> 
>> 
>> 
>> _______________________________________________
>> Servercert-wg mailing list
>> Servercert-wg at cabforum.org <mailto:Servercert-wg at cabforum.org>
>> https://lists.cabforum.org/mailman/listinfo/servercert-wg <https://lists.cabforum.org/mailman/listinfo/servercert-wg>
>> 
>> 
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